Dirigo

Data processing agreement

Updated 27 October 2026.

1. Parties and roles

This agreement is part of the terms of service between the Customer and CodeAPIness SHPK, tax ID (NIPT) M12305008A, at Rruga "Sotir Çaçi", Njësia Bashkiake nr. 3, Tirana (the "Processor"). For the personal data the Customer puts in Dirigo, or that arises from its use, the Customer is the controller and we are the processor. It applies under Albanian personal data protection law and, where applicable, Regulation (EU) 2016/679 (GDPR).

2. Subject and duration

We process personal data only to provide Dirigo to the Customer: showing and playing content on its screens, the panel, screen monitoring and alerts. Processing lasts as long as the subscription, plus the deletion periods in the privacy policy.

3. Data and data subjects

Dirigo is not meant for special categories of data; the Customer does not put them on screens without a legal basis.

4. Our obligations

5. Sub-processors

The Customer authorises the sub-processors in section 5 of the privacy policy: Hetzner Online GmbH, Cloudflare, Inc. and Sendinblue SAS (Brevo). We notify the Customer of a new sub-processor by email 30 days in advance; if the Customer objects with reason, it may end the subscription before that date. We require the same data protection obligations from sub-processors.

Google Drive is the Customer's own account; Google is not our sub-processor for the content.

6. Transfers abroad

Data is stored in the European Union. When a sub-processor processes it outside the EU, we rely on the European Commission's standard contractual clauses or an adequacy decision.

7. Contact

[email protected].